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NOTICE OF IMMIGRATION CONSEQUENCES
If you are not a United States citizen, a plea of guilty to any offense, a conviction by trial verdict, or a youthful
offender adjudication subjects you to a risk that adverse consequences will be imposed on you by the United Statesimmigration authorities, including, but not limited to, removal from the United States, exclusion from admission to theUnited States, and/or denial of naturalization. Because the immigration consequences applicable in your particular
case may depend on factors such as your current immigration status, your length of residence in the United States, and
your previous criminal history, you should consult with your attorney for advice specific to your circumstances.
The following are designated as deportable offenses under 8 U.S.C. 1227(a)(2), and any non-citizen
convicted of such an offense (within the meaning of 8 U.S.C. 1101[a][48]) shall, upon order of the AttorneyGeneral, be removed (8 U.S.C. 1227[a]), regardless of whether the offense is a felony, a misdemeanor, or any other
offense under State law:
any controlled substance or marihuana offense (other than a first offense involvingpossession for ones own use of 30 grams or less of marihuana);
any offense involving a firearm, any domestic violence offense or violation of an order of
protection, any stalking offense or crime of child abuse, and failure to register as a sex offender;
any offense designated an aggravated felony under 8 U.S.C. 1101(a)(43), including, butnot limited to: murder; rape; any controlled substance or firearm trafficking offense; bail jumping;
burglary, robbery, receipt of stolen property, or any other theft-related offense or crime of violencefor which a sentence of one year or more is imposed; or any offense involving money laundering ofmore than $10,000 or fraud, deceit or tax evasion in which the loss to the victim(s) is more than
$10,000; and
many other offenses described in 8 U.S.C. 1227(a)(2).
In addition, if the offense constitutes an aggravated felony, or if you are not a lawful permanent resident of
the United States (or have not been such for at least five years with at least seven years continuous residency) and the
offense is any deportable offense, there will be additional consequences, including, but not limited to, your ineligibilityfor discretionary cancellation of removal by the Attorney General.
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NOTIFICACIN SOBRE CONSECUENCIAS INMIGRATORIAS
Si usted no es ciudadano de los Estados Unidos, una declaracin de culpabilidad por cualquier
ofensa, un veredicto condenatorio mediante un juicio o una declaracin como ofensor juvenil lo har sujetoal riesgo de que las autoridades inmigratorias de los Estados Unidos le impongan consecuencias adversas,
que incluyen, sin que estas se limiten a, su expulsin de Los Estados Unidos, exclusin de ser admitido a los
Estados Unidos, y/o el rechazo de su solicitud para la ciudadana o naturalizacin. Debido a que las
consecuencias de inmigracin aplicables a su caso en particular pueden depender de factores como su
estado de inmigracin actual, el tiempo que lleva viviendo en los Estados Unidos y sus antecedentes
penales, usted debe consultar a su abogado para asesora especfica a sus circunstancias.
Las siguientes ofensas han sido clasificadas como aquellas que implican deportacin de acuerdo a laley 8 U.S.C. 1227(a)(2), y cualquiera que no sea ciudadano y sea condenado por tal ofensa (como lodefine la ley 8 U.S.C. 1101[a][48]) deber, bajo ordenes del Procurador General, ser expulsado de los
Estados Unidos (8 U.S.C. 1227[a]), sin importar si la ofensa es un delito mayor, un delito menor, o
cualquier otra ofensa segn las leyes estatales:
cualquier ofensa por sustancias reguladas o marihuana (excepto la primera ofensa
relacionada con posesin de 30 gramos de marihuana o menos para uso propio);
cualquier ofensa que incluya un arma de fuego, cualquier ofensa por violencia
domstica o violacin de una orden de proteccin, cualquier ofensa por acechar o delito
por maltrato de menores, e incumplimiento a registrarse como ofensor sexual;
cualquier ofensa clasificada como un delito con agravante de acuerdo a la ley 8
U.S.C. 1101(a)(43), incluyendo, y sin que estas se limiten a: homicidio; violacin
sexual; cualquier ofensa por trfico de sustancias reguladas o de armas de fuego; huir
estando bajo fianza, entrar sin autorizacin en propiedad ajena con la intencin de cometer
un crimen, robo, recepcin de propiedad robada, o cualquier otra ofensa relacionada conrobo o un delito de violencia por el cual se haya impuesto una condena de un ao o ms; o
cualquier ofensa relacionada con el lavado de dinero por ms de $10,000 o un fraude,
t f i d i t l l did d l ( ) ti ( ) d
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/
8 U.S.C. 1227(a)(2)
( 8
U.S.C. 1101 [a][48] )
(8 U.S.C. 1227 [a])
30
8 U.S.C. 1101 (a)(43)
$10,000
$10,000
8 U.S.C. 1227 (a)(2) (
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
THE PEOPLE OF THE STATE OF NEW YORK
-against-
Vadim Polyakov,
Daniel Petryszyn,
Laurence Brinkmeyer,Bryan Caputo,
Sergei Kirin,
Nikolay Matveychuk,
Defendants.
THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses the
defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of MONEY
LAUNDERING IN THE FIRST DEGREE, in violation of Penal Law 470.20(1)(b)(ii)(A)(iii),
committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
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FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
PROPERTY IN THE FOURTH DEGREE, in violation of Penal Law 165.45(1), committed as
follows:
The defendants Vadim Polyakov and Daniel Petryszyn, in the County of New York and
elsewhere, on or about April 8, 2013, with intent to benefit themselves, and a person other than an
owner thereof and to impede the recovery by an owner thereof, knowingly possessed stolen property
owned by StubHub LLC, and the value of the property exceeded one thousand dollars.
FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn, of the crime of CRIMINAL POSSESSION OF STOLEN
PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50 committed as
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SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
PROPERTY IN THE FOURTH DEGREE, in violation of Penal Law 165.45(1), committed as
follows:
The defendants Vadim Polyakov and Daniel Petryszyn, in the County of New York and
elsewhere, on or about April 24, 2013, with intent to benefit themselves, and a person other than an
owner thereof and to impede the recovery by an owner thereof, knowingly possessed stolen property
owned by StubHub LLC, and the value of the property exceeded one thousand dollars.
SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
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EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation
of Penal Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan
Caputo, in the County of New York and elsewhere, on or about April 26, 2013, with intent to
benefit themselves, and a person other than an owner thereof and to impede the recovery by an
owner thereof, knowingly possessed stolen property owned by StubHub LLC, and the value of the
property exceeded three thousand dollars.
NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation
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TENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation
of Penal Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan
Caputo, in the County of New York and elsewhere, on or about May 12, 2013, with intent to benefit
themselves, and a person other than an owner thereof and to impede the recovery by an owner
thereof, knowingly possessed stolen property owned by StubHub LLC, and the value of the property
exceeded three thousand dollars.
ELEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of
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TWELFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation
of Penal Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan
Caputo, in the County of New York and elsewhere, on or about May 16, 2013, with intent to benefit
themselves, and a person other than an owner thereof and to impede the recovery by an owner
thereof, knowingly possessed stolen property owned by StubHub LLC, and the value of the property
exceeded three thousand dollars.
THIRTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
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FOURTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer in the County
of New York and elsewhere, on or about June 12, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FIFTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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SIXTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal
Law 165.45(1), committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about July 14, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded one
thousand dollars.
SEVENTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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EIGHTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about July 19, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
NINETEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
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TWENTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about July 30, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
TWENTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
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TWENTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about August 6, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
TWENTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
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TWENTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about August 14, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
TWENTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal
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TWENTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about September 4, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
TWENTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
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THIRTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about September 8, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
THIRTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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THIRTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about September 20, 2013, with intent to benefit themselves, and
a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
THIRTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal
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THIRTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about September 22, 2013, with intent to benefit themselves, and
a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
THIRTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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THIRTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about September 30, 2013, with intent to benefit themselves, and
a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
THIRTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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THIRTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal
Law 165.45(1), committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about October 4, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded one
thousand dollars.
THIRTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
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FORTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about October 13, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FORTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50, committed as
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FORTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about November 24, 2013, with intent to benefit themselves, and
a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FORTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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FORTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about December 4, 2013, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FORTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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FORTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about December 11, 2013, with intent to benefit themselves, and
a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FORTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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FIFTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about December 16, 2013, with intent to benefit themselves, and
a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FIFTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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FIFTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50, committed as
follows:
The defendants Vadim Polyakov and Daniel Petryszyn, in the County of New York and
elsewhere, on or about December 29, 2013, with intent to benefit themselves, and a person other
than an owner thereof and to impede the recovery by an owner thereof, knowingly possessed stolen
property owned by StubHub LLC, and the value of the property exceeded three thousand dollars.
FIFTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN
PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50, committed as
follows:
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FIFTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about January 8, 2014, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FIFTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
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FIFTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants
Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL
POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal
Law 165.50, committed as follows:
The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County
of New York and elsewhere, on or about January 12, 2014, with intent to benefit themselves, and a
person other than an owner thereof and to impede the recovery by an owner thereof, knowingly
possessed stolen property owned by StubHub LLC, and the value of the property exceeded three
thousand dollars.
FIFTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
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FIFTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
April 19, 2013, with intent to benefit himself and a person other than an owner thereof and to
impede the recovery by an owner thereof, knowingly possessed stolen property owned by a second
individual known to the Grand Jury and the property consisted of a second credit card ending 8480.
FIFTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
April 23, 2013, with intent to benefit himself and a person other than an owner thereof and to
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SIXTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
April 23, 2013, with intent to benefit himself and a person other than an owner thereof and to
impede the recovery by an owner thereof, knowingly possessed stolen property owned by a fourth
individual known to the Grand Jury and the property consisted of a fourth credit card ending 7168.
SIXTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
4, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
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SIXTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
7, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
recovery by an owner thereof, knowingly possessed stolen property owned by a sixth individual
known to the Grand Jury and the property consisted of a sixth credit card ending 9030.
SIXTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
8, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
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SIXTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
12, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
recovery by an owner thereof, knowingly possessed stolen property owned by a eighth individual
known to the Grand Jury and the property consisted of an eighth credit card ending 6945.
SIXTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
15, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
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SIXTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
15, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
recovery by an owner thereof, knowingly possessed stolen property owned by a tenth individual
known to the Grand Jury and the property consisted of a tenth credit card ending 5224.
SIXTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about June
1, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
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SIXTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about July
15, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the
recovery by an owner thereof, knowingly possessed stolen property owned by a twelfth individual
known to the Grand Jury and the property consisted of a twelfth credit card ending 7698.
SIXTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
August 11, 2013, with intent to benefit himself and a person other than an owner thereof and to
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SEVENTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
August 11, 2013, with intent to benefit himself and a person other than an owner thereof and to
impede the recovery by an owner thereof, knowingly possessed stolen property owned by a
fourteenth individual known to the Grand Jury and the property consisted of a fourteenth credit card
ending 6842.
SEVENTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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SEVENTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 5, 2013, with intent to benefit himself and a person other than an owner thereof and to
impede the recovery by an owner thereof, knowingly possessed stolen property owned by a sixteenth
individual known to the Grand Jury and the property consisted of a sixteenth credit card ending
6228.
SEVENTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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SEVENTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 5, 2013, with intent to benefit himself and a person other than an owner thereof and to
impede the recovery by an owner thereof, knowingly possessed stolen property owned by an
eighteenth individual known to the Grand Jury and the property consisted of an eighteenth credit
card ending 5952.
SEVENTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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EIGHTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 20, 2013, with intent to benefit himself and a person other than an owner thereof and to
impede the recovery by an owner thereof, knowingly possessed stolen property owned by a twenty-
fourth individual known to the Grand Jury and the property consisted of a twenty-fourth credit card
ending 9004.
EIGHTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN
THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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EIGHTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
April 18, 2013, knowingly and with intent to defraud assumed the identity of another person by
presenting himself as that other person, and by acting as that other person, and by using personal
identifying information of that other person and thereby obtained goods and property, and used
credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.
EIGHTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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EIGHTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
4, 2013, knowingly and with intent to defraud assumed the identity of a fifth person by presenting
himself as that other person, and by acting as that other person, and by using personal identifying
information of that other person and thereby obtained goods and property, and used credit in the
name of such other person in an aggregate amount that exceeded five hundred dollars.
EIGHTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
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NINETIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
8, 2013, knowingly and with intent to defraud assumed the identity of a seventh person by
presenting himself as that other person, and by acting as that other person, and by using personal
identifying information of that other person and thereby obtained goods and property, and used
credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.
NINETY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
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NINETY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
15, 2013, knowingly and with intent to defraud assumed the identity of a ninth person by presenting
himself as that other person, and by acting as that other person, and by using personal identifying
information of that other person and thereby obtained goods and property, and used credit in the
name of such other person in an aggregate amount that exceeded five hundred dollars.
NINETY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May
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NINETY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about June
1, 2013, knowingly and with intent to defraud assumed the identity of a eleventh person by
presenting himself as that other person, and by acting as that other person, and by using personal
identifying information of that other person and thereby obtained goods and property, and used
credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.
NINETY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about July
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NINETY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
August 11, 2013, knowingly and with intent to defraud assumed the identity of a thirteenth person
by presenting himself as that other person, and by acting as that other person, and by using personal
identifying information of that other person and thereby obtained goods and property, and used
credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.
NINETY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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NINETY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 4, 2013, knowingly and with intent to defraud assumed the identity of a fifteenth person
by presenting himself as that other person, and by acting as that other person, and by using personal
identifying information of that other person and thereby obtained goods and property, and used
credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.
NINETY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
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ONE HUNDREDTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 5, 2013, knowingly and with intent to defraud assumed the identity of a seventeenth
person by presenting himself as that other person, and by acting as that other person, and by using
personal identifying information of that other person and thereby obtained goods and property, and
used credit in the name of such other person in an aggregate amount that exceeded five hundred
dollars.
ONE HUNDRED AND FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
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ONE HUNDRED AND SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 7, 2013, knowingly and with intent to defraud assumed the identity of a nineteenth
person by presenting himself as that other person, and by acting as that other person, and by using
personal identifying information of that other person and thereby obtained goods and property, and
used credit in the name of such other person in an aggregate amount that exceeded five hundred
dollars.
ONE HUNDRED AND THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
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ONE HUNDRED AND FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 8, 2013, knowingly and with intent to defraud assumed the identity of a twenty-first
person by presenting himself as that other person, and by acting as that other person, and by using
personal identifying information of that other person and thereby obtained goods and property, and
used credit in the name of such other person in an aggregate amount that exceeded five hundred
dollars.
ONE HUNDRED AND FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
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ONE HUNDRED AND SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
September 9, 2013, knowingly and with intent to defraud assumed the identity of a twenty-third
person by presenting himself as that other person, and by acting as that other person, and by using
personal identifying information of that other person and thereby obtained goods and property, and
used credit in the name of such other person in an aggregate amount that exceeded five hundred
dollars.
ONE HUNDRED AND SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
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ONE HUNDRED AND EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
December 2, 2013, knowingly and with intent to defraud assumed the identity of a twenty-fifth
person by presenting himself as that other person, and by acting as that other person, and by using
personal identifying information of that other person and thereby obtained goods and property, and
used credit in the name of such other person in an aggregate amount that exceeded five hundred
dollars.
ONE HUNDRED AND NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
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ONE HUNDRED AND TENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation
of Penal Law 190.79(1), committed as follows:
The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about
December 13, 2013, knowingly and with intent to defraud assumed the identity of a twenty-seventh
person by presenting himself as that other person, and by acting as that other person, and by using
personal identifying information of that other person and thereby obtained goods and property, and
used credit in the name of such other person in an aggregate amount that exceeded five hundred
dollars.
ONE HUNDRED AND ELEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Nikolay Matveychuk of the crime of GRAND LARCENY IN THE FOURTH DEGREE, in
violation of Penal Law 155.30(1), committed as follows:
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ONE HUNDRED AND TWELFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Nikolay Matveychuk of the crime of MONEY LAUNDERING IN THE 4TH DEGREE, in
violation of Penal Law 470.05(1)(a)(ii)(A)(b), committed as follows:
The defendant Nikolay Matveychuk, in the County of New York and elsewhere, during the
period from on or about April 26, 2013 to on or about October 14, 2013, knowing that the property
involved in one or more financial transactions represented the proceeds of criminal conduct,
conducted one or more such financial transactions which in fact involved the proceeds of specified
criminal conduct, knowing that the transaction or transactions in whole or in part were designed to
conceal and disguise the nature, the location, the source, the ownership, and control of the proceeds
of criminal conduct and the total value of the property involved in such financial transaction or
transactions exceeded five thousand dollars.
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ONE HUNDRED AND THIRTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Bryan Caputo of the crime of MONEY LAUNDERING IN THE 4TH DEGREE, in violation of
Penal Law 470.05(1)(a)(ii)(A)(b), committed as follows:
The defendant Bryan Caputo, in the County of New York and elsewhere, during the period
from on or about April 26, 2013 to on or about May 21, 2013, knowing that the property involved in
one or more financial transactions represented the proceeds of criminal conduct, conducted one or
more such financial transactions which in fact involved the proceeds of specified criminal conduct,
knowing that the transaction or transactions in whole or in part were designed to conceal and
disguise the nature, the location, the source, the ownership, and control of the proceeds of criminal
conduct and the total value of the property involved in such financial transaction or transactions
exceeded five thousand dollars.
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ONE HUNDRED AND FOURTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Nikolay Matveychuk of the crime of UNLAWFUL POSSESSION OF PERSONAL
IDENTIFICATION INFORMATION IN THE THIRD DEGREE, in violation of Penal Law
190.81, committed as follows:
The defendant Nikolay Matveychuk, in the County of New York and elsewhere, on or about
September 4, 2013, knowingly possessed a person's financial services account number and code,
savings account number and code, checking account number and code, credit card account number
and code, debit card number and code, personal identification number, mother's maiden name,
computer system password, and electronic signature, knowing such information was intended to be
used in furtherance of the commission of a crime defined in the Penal Law.
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ONE HUNDRED AND FIFTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Nikolay Matveychuk of the crime of UNLAWFUL POSSESSION OF PERSONAL
IDENTIFICATION INFORMATION IN THE THIRD DEGREE, in violation of Penal Law
190.81, committed as follows:
The defendant Nikolay Matveychuk, in the County of New York and elsewhere, on or about
September 7, 2013, knowingly possessed a person's financial services account number and code,
savings account number and code, checking account number and code, credit card account number
and code, debit card number and code, personal identification number, mother's maiden name,
computer system password, and electronic signature, knowing such information was intended to be
used in furtherance of the commission of a crime defined in the Penal Law.
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ONE HUNDRED AND SIXTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Nikolay Matveychuk of the crime of UNLAWFUL POSSESSION OF PERSONAL
IDENTIFICATION INFORMATION IN THE THIRD DEGREE, in violation of Penal Law
190.81, committed as follows:
The defendant Nikolay Matveychuk, in the County of New York and elsewhere, on or about
September 7, 2013, knowingly possessed a person's financial services account number and code,
savings account number and code, checking account number and code, credit card account number
and code, debit card number and code, personal identification number, mother's maiden name,
computer system password, and electronic signature, knowing such information was intended to be
used in furtherance of the commission of a crime defined in the Penal Law.
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ONE HUNDRED AND SEVENTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
Sergei Kirin of the crime of MONEY LAUNDERING IN THE SECOND DEGREE, in violation
of Penal Law 470.15(1)(b)(ii)(A)(iii), committed as follows:
The defendant Sergei Kirin, in the County of New York and elsewhere, during the period
from on or about August 21, 2013 to on or about March 4, 2014, knowing that the property involved
in one or more financial transactions represented the proceeds of specified criminal conduct, he or
she conducts one or more financial transactions which in fact involved the proceeds of specified
criminal conduct, knowing that the transaction or transactions in whole or in part were designed to
conceal and disguise the nature, the location, the source, the ownership, and control of the proceeds
of specified criminal conduct and the total value of the property involved in such financial
transaction or transactions exceeded one hundred thousand dollars.
CYRUS R. VANCE, JR.
District Attorney
GJ # 10 Case # 3A
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Filed: NA for all Defendants
No.
THE PEOPLE OF THE STATE OF NEW YORK
-against-
Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer,
Bryan Caputo, Nikolay Matveychuk, Sergei Kirin,
Defendants.
INDICTMENT
MONEY LAUNDERING IN THE FIRST DEGREE, P.L. 470.20(1)(b)(ii)(A)(iii) - DEF. V. Polyakov, D. Petryszyn, L. Brinkmeyer
GRAND LARCENY IN THE FIRST DEGREE, P.L. 155.42 - DEF. V. Polyakov
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE SECOND DEGREE, P.L. 165.52 - DEF. V. Polyakov, D. Petryszyn,CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, P.L. 165.50 - DEF. V. Polyakov, 46 Cts, D. Petryszyn, 46 Cts, L. Brinkmeyer,
40 Cts, B. Caputo, 5 Cts
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, P.L. 165.45(1) - DEF. V. Polyakov, 7 Cts, D. Petryszyn, 7 Cts, L.
Brinkmeyer, 4 Cts
CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, P.L. 165.45(2) - DEF. V. Polyakov, 27 Cts
IDENTITY THEFT IN THE SECOND DEGREE, P.L. 190.79(1) - DEF. V. Polyakov, 27 Cts
GRAND LARCENY IN THE FOURTH DEGREE, P.L. 155.30(1) - DEF. N. Matveychuk
MONEY LAUNDERING IN THE FOURTH DEGREE, P.L. 470.05(1)(a)(ii)(A)(b) - DEF. N. Matveychuk
MONEY LAUNDERING IN THE FOURTH DEGREE, P.L. 470.05(1)(a)(ii)(A)(b) - DEF. B. Caputo
UNLAWFUL POSSESSION OF PERSONAL IDENTIFICATION INFORMATION IN THE THIRD DEGREE, P.L. 190.81 - DEF. N. Matveychuk, 3 CtsMONEY LAUNDERING - 2ND CONCEAL OWNERSHIP, P.L. 470.15(1)(b)(ii)(A) - DEF. S. Kirin
CYRUS R. VANCE, JR., District Attorney
A True Bill
N. David Neeman
Cybercrime and Identity Theft Bureau Foreman
ADJOURNED TO PART _______ ON ________
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